OSHA placing heavy focus on how employees who speak Spanish are trained and kept safe at work

If OSHA visits your workplace, through either an Employee complaint or some other inspection trigger, be prepared to explain and show how your company provides non-English-speaking employees with safety training.

This has been high on the routine list of questions for employers who have contacted Safety Advantage for OSHA assistance over the last six months.  

In our experience, some employers are too quick to assume that their Spanish-speaking workers "really do understand what we're telling them."  One construction site contractor recently tried to defend their new hire safety orientation given in English when more than 60 percent of the routine workforce speaks mainly Spanish.  That's a hard sell -- to OSHA, during litigation, or just about any circumstance when a company's actions need to make sense.

Documents and materials translated into Spanish are a good start.  But how well can site managers communicate with workers under their direct supervision whose primary language is NOT English?  Employers would do well to give their work site communications a solid reality check before they bet the farm on an easy answer.

Also, consider that many workers in labor-heavy assignments may not be getting much safety information at all through reading brochures, pamphlets or sign-off sheets.  Have you sufficiently assessed the reading skills of your workforce?  It could be a huge issue if you ever have to defend written documentation as your primary source of safety and OSHA compliance information to employees.

Planning for bilingual success

Tailoring your safety program, orientations and training to need the needs of your Spanish-speaking employees can make the workplace much, much safer. 

Begin with a site-specific safety orientation

Prior to beginning a job assignment, each employee should receive an initial safety orientation. If an individual has a basic understanding of  English, an effective (and defensible) safety orientation might be provided simply by speaking slowly and asking questions to confirm the employee's understanding. 

When in doubt of the individual's understanding of information presented, give the orientation in Spanish or the employee's primary language.  Written and illustrated materials in the language that the worker best understands always makes sense.

Avoid when possible giving information to a "mixed language" group by saying everything in English and then the other language.  This is slow, repetitive and is almost guaranteed to keep everyone at the meeting from paying close attention to the information presented.

Keep in mind why this process is important:  If any employee is not told the rules and shown how to do a task safely, the employer is not fulfilling a basic legal as well as management requirements.  On the human resources side, it is difficult to hold employees accountable for not  following rules or work procedures that they were never told about.

Detailed and technical information

When non-English speaking personnel need training and certification in more technical areas (for example, forklift certification) communication of terms and equipment descriptions may special translation efforts.

Visual presentations and PowerPoint® presentations need to be in the audience's main language.  Bilingual instructors should be comfortable with the way the terms are carried over from English.

Emergency response and evacuation procedures

Make sure that facility evacuation plans, maps and procedures are  translated into Spanish and included in the first day's orientation. 

Safety representatives, committees and employee meetings

Spanish-speaking workers need to be involved with regular safety activities, meetings and the safety committee.  This representative should take notes or minutes of meetings in Spanish to help ensure that safety news is communicated properly to the non-English-speaking employees.  Their comments and feedback are essential.

Manufacturer's instructions and manuals

Employees who will be using powered tools, equipment or machines should be trained based on the manufacturer's instructions and manuals. Most contemporary manuals come in two or three languages.  If you only have them in English, call the manufacturer for a Spanish version.

Also, make sure that safety labels, postings and warnings on machines or equipment are in English and Spanish.